Privacy Policy

Effective date, 24/5/2023

This Privacy Policy, alongside Our Cookie Policy, explains how we handle your personal data. These two policies are inseparable and should be construed accordingly.

All changes go into effect immediately.


1. WHO SHOULD READ THIS PRIVACY POLICY?
This Privacy Policy explains how We collect, use, process, or delete personal data of Our website visitors and/or Our Customers.

This Privacy Policy applies to all our Website Users and Our Customers.

This Privacy Policy provides important information about:
What information do we collect and why do we collect it;

How we use that information, and the lawful bases we rely on for doing so;

How you can exercise your statutory rights such as the right to deletion and the right to access your data.


2. WHO IS DATA CONTROLLER?
Business Name: MakeWell Europe Ltd.
Website for the UK: https://www.makewellnutrition.co.uk
Website for the EU: https://www.makewellforyou.eu/
Business Address: 4th Floor Silverstream House, 45 Fitzroy Street, London, England, W1T 6EB
Business Phone number: + 44 (0)20 4530 9526
Business email for the EU: hello@makewellforyou.eu
Business email for the UK: hello@makewellnutrition.co.uk


3. DEFINITIONS
“Account” means the user account Our users can create on our Website,
“Data Processor” means an entity that processes Personal Data on Our behalf,
“Personal data” means any piece of information that relates to an identified or identifiable individual as defined under the UK and the EU GDPR,
“Us”, “We”, and “Data Controller” mean MakeWell Europe Ltd. as defined in Section 2.
“Website” means https://www.makewellnutrition.co.uk and https://www.makewellforyou.eu
“User” means any person who visits and/or browses through Our website,

For any term not defined in this Privacy policy, the definitions set out in the Terms & Conditions shall apply.


4. WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT ABOUT YOU?
We may collect the following types of personal data about You:

A. Basic personal details
When You create an Account on Our Website when You contact Us via different methods such as email, or when You place an Order for the purchase of goods, we collect the following types of personal details about you:

Your name-surname,

Your billing and delivery address,

Your phone number,

Your email,

The country in which you are located.

B. Data about Your visit to and Your use of our Website
When you browse our Website and use its features, we collect and process your data which may include, but are not limited to:

Pages you viewed,

How much time you spend on which page,

Previous URLs you visited and pages you viewed,

How you interact with our website,

How you arrive on our website (via social media or Google search, etc)

Your IP address,

Your operating system,

Information about your devices such as your device ID and browser type

We may use a variety of technologies such as tracking cookies, third-party analytics tools, social media plugins, and web beacons to collect such data.

For more details, please refer to Our Cookie Policy.

C. Payment details
When processing and confirming Your Order, we collect financial data about you such as

Credit/debit card number,

CVV number,

card expiration date,

and Bank account details


5. HOW DO WE COLLECT YOUR PERSONAL DATA
We collect, process, and use your personal data via the following methods:

Data You voluntarily disclose to Us
When You create an account on Our Website when You place an order, when you contact us, or When You make a payment, You directly provide Us with Your personal data.

For example, You provide your billing address, credit/debit card details, and your name when You submit an Order.

When You create an Account, You provide us with your name, surname, billing address, and email address.

Data We automatically collect from you
We use a variety of technologies such as cookies, analytics tools, and web beacons to automatically collect information about how you browse our Website.

For example, we use Google Analytics to collect information about your behaviour across our Website, your browser type and your operating system, and your device ID.


6. PURPOSES FOR PROCESSSING OF YOUR PERSONAL DATA
When We collect, use and process your personal data to achieve the following purposes:

TO PERFORM OUR CONTRACTUAL OBLIGATIONS
We collect, use or share your personal data to fulfil our contractual obligations:

Payment: We process your payment details such as your card number, CVC number, and your billing address to complete payment and confirm the order,

Shipping, and Delivery: We collect and use your name, surname, and delivery address to deliver the ordered goods to the address You provided on the Order form. We share these details with shipping and delivery service providers.

TO IMPROVE OUR WEBSITE, ITS CONTENT, AND FEATURES
We collect, use, and analyse your personal data such as your behaviour across our website and the previous websites you visited. We may then use such data to improve our Website, its content, and its features.

For more detailed information, please refer to our Cookie Policy.

TO PREVENT FRAUD AND TO COMPLY WITH APPLICABLE LAWS AND REGULATIONS
We may collect, process, or share your data to comply with applicable laws and regulations and to prevent fraudulent activities.

FOR ADVERTISEMENT AND MARKETING ACTIVITIES
We may use your email address, your postal address, and your phone number to provide You with marketing and advertising materials.

These marketing & promotional activities may include.

Newsletter email campaigns: When you subscribe to our email newsletters, we may use your email address to send you marketing & promotional materials.

Advertising by Post: We may use your name, surname, and your postal address details to send you advertising materials by post.

TO PROVIDE YOU WITH OUR WEBSITE, ITS CONTENT, AND ITS FEATURES
We process your personal data such as your IP address, your browser type, your name surname, and other basic details to allow You to access our website and its content and use its features.

For example, We collect your basic personal details such as your email name and email address to enable you to create an account.


7. LEGAL BASES WE RELY ON TO PROCESS YOUR DATA
Under the UK and EU GDPR, we are required to identify a legal basis to process your personal data.

We rely on the following legal basis under the UK and the EU GDPR.

CONSENT
We rely on your consent in accordance with article 6.1 (a) of the GDPR when we process your data in the following ways:

When we use your data to send you marketing and promotional materials via email, phone, or post.

When We use cookies and other similar technologies other than those strictly necessary cookies. (Visit our cookie policy to learn more)

When we use your data for analytics and measurement purposes, we rely on your consent.

LEGITIMATE INTERESTS
We rely on Legitimate Interests ground under article 6.1. (b) GDPR to collect and process your data by storing strictly necessary cookies on your device.

We rely on legitimate interests to collect and use your personal data to carry out B2B marketing activities such as email marketing.

We rely on our legitimate interests to prevent fraud.

CONTRACTUAL NECESSITY
When we collect, use, share, or otherwise process your personal data to fulfill our contractual obligations, we rely on “contractual necessity” ground under the GDPR.

This includes;

Collecting your payment details,

Collecting, storing, and sharing your personal data for shipping and delivery purposes.


8. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
We only share your personal data with third parties when one of the following applies:

When we obtain your consent to disclose your data to third parties such as when you consent to the use of third-party tracking technologies, cookies.

Where we provide personal data to third parties to perform our contractual obligations and carry out administrative tasks such as payment processing, customer service, email marketing, web hosting, and email marketing.

Where we are under a legal obligation to share your data with legal/regulatory authorities upon a valid and lawful request or to comply with applicable laws.

To detect and prevent fraud, security, and other technical issues.


9. DATA RETENTION AND DELETION
How long do we retain your Personal Data?
We will store Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

We will retain Your Personal Data to the extent that it is necessary to satisfy our legal obligations. For instance, this may cover situations where we need to store your data to bring legal claims or for any dispute resolution process.

When we no longer need to retain your data, we may use one of the following to delete it:

Erasure

Overwriting data

Deletion/Reformatting


10. YOUR STATUTORY RIGHTS UNDER THE GDPR
All visitors/customers located in the UK & EEA area are entitled to the following:

Right to be Informed: You have the right to be informed about the personal data we collect from you, and how we process it.

Right of Access: You may request to see and obtain copies of the personal data we have about you and whether we process your data;

Right to rectification: You may request that we correct any inaccuracies in the personal data that we have about you;

Right to Be Forgotten: In certain circumstances, you may (unless other grounds set forth in the law applies) exercise your right to be forgotten (have your personal data erased);

Right to Restriction: You may request to restrict the processing of your data because there is some disagreement about its accuracy or objections against its legitimate usage – i.e. requesting that we do not process your personal data for direct marketing purposes. We can do this by keeping a single record of your data on a suppression list;

Right to Object: You may raise objections to our processing of your personal data if we are relying on legitimate interest as the lawful ground for data processing; and

Right to Data Portability: If applicable, you may ask for your personal data to be transferred to another organisation.


11. HOW TO EXERCISE YOUR RIGHTS
You can exercise your statutory rights defined in section 10 via one of the following methods:

Application by post: MakeWell Europe Ltd., 4th Floor Silverstream House, 45 Fitzroy Street, London, England, W1T 6EB

Application via email:
EU users/customers: hello@makewellforyou.eu
UK users/customers: hello@makewellnutrition.co.uk

Be advised to include the following when you submit a request:

Description of your request in sufficient detail,

provide us with your contact details

We will email you to verify the authenticity of your request to exercise your rights.

We endeavour to respond to your request within the time limits imposed by relevant applicable laws.


12. HOW TO LODGE A COMPLAINT WITH DATA PROTECTION AUTHORITIES
If you live in UK & EEA:
If you reside in the EEA or the UK, you can submit a complaint with the Data Protection Authority within your country.

If you live in the UK, you can contact the ICO in the following ways:
The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

To learn about country-specific complaint processes, please refer to the websites of the competent Data Protection Authorities of the country in which you reside.


13. THIRD-PARTY SERVICE PROVIDERS
We use third-party service providers to provide Our Website, perform our contractual duties, and improve our services.

When we use third-party services, we enter into data processing agreements with those parties as required under article 28 GDPR. This agreement sets out both Our and Our vendors’ obligations.

To get more detailed information about each third-party service provide we use, please email us at: hello@makewellnutrition.co.uk and hello@makewellforyou.eu

List of our third-party vendors and purposes for which we use their services

Vendor details Purposes of data processing

Customer service software

Email marketing

To run affiliate marketing campaigns

To run affiliate marketing programs

To process payments

Livestorm Webinars
https://livestorm.co/

To provide our webinar services

Huboo
Huboo Technologies Ltd. (Fulfilment)
https://www.huboo.com/

Fulfillment services

Pricing and discount management

File, document and data storage

Logistics companies such as Royal Mail, Evri, FedEX and DHL

Contact Us for more information about which provider we use for your order


Meta Conversions API and Meta Pixel Privacy Notice
We collect, use, and share your personal data with Meta, using Meta Pixel and Meta Conversions API on our website.

Meta Pixel is a javascript code embedded on our website to collect data about how you, as our website visitor, interact with our website such as what pages you click on, and what purchases you make.

Meta Conversions API allows us to connect the data we collect via our website to Meta to serve more relevant ads to you and optimize our marketing campaigns.

Types of data collected How we use this data The legal basis we rely on

Facebook Pixel

HTTP Headers, IP addresses, information about the web browser, page location, document, referrer, and the person using the website.

Buttons clicked by site visitors, the labels of those buttons, and any pages visited as a result of the button clicks.

Conversion events.

Email address.

To improve the effectiveness of our marketing campaigns.

To serve you more personalized ads on Facebook.

To share your data with Facebook.

To retarget you with our ads and marketing emails.

We rely on consent to collect and use your data in accordance with Article 6 of the EU and the UK GDPR.

Facebook Conversions API

Page visits.

Web conversions such as sales and signups.

Name, Location, Email address and phone number, and your browsing behavior on our website.

To improve the effectiveness of our marketing campaigns.

To serve you more personalized ads on Facebook.

To share your data with Meta.

To retarget you with our ads and marketing emails.

We rely on consent to collect and use your data in accordance with Article 6 of the EU and the UK GDPR.


To learn more about Meta Pixel, please visit this page:
https://developers.facebook.com/docs/meta-pixel/ 

To learn more about Meta Conversions API:
https://www.facebook.com/business/help 

How Meta collects and uses your data via Meta pixel and Conversions API:
https://www.facebook.com/privacy/policy/


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4. DATA SECURITY
We implement state-of-the-art technical, organisational, and contractual measures to ensure the security of your personal data.

To get more information about the security measures we implement, contact us at hello@makewellnutrition.co.uk or hello@makewellforyou.eu


15. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy at our sole discretion.

We will notify users in advance of the changes by a prominent notification on our website and via email if they are registered with an account.


16. HOW TO CONTACT US
For any questions You may have regarding this Privacy Policy, you should contact us at:

Registered Business name: MakeWell Europe Ltd

Mailing address: 4th Floor Silverstream House, 45 Fitzroy Street, London, England W1T 6EB

Phone number: + 44 (0)20 4530 9526

Business email for the EU: hello@makewellforyou.eu
Business email for the UK: hello@makewellnutrition.co.uk

 

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